June 2026 Outbound Immigration and Global Mobility Recap | EMEA

Clark Hill’s Outbound Immigration & Global Mobility practice guides corporate clients and individuals through complex global immigration challenges worldwide. We pride ourselves on creative, compliant, and people-centered solutions – looking at global mobility from a wholistic perspective in an ever-changing immigration environment. Our team assists with short-term assignments, long-term relocations, consular processing, document procurement, document legalizations/apostilles, and business visas in 100+ countries worldwide.

Below is an overview of the major updates from June 2026 in the Europe, Middle East, and Africa region.

European Union

EU Talent Pool Regulation Applies from June 2026

Regulation (EU) 2026/1047 establishing the EU Talent Pool is now in effect. The Regulation creates an EU-level framework for a digital platform intended to connect employers in participating Member States with third-country jobseekers residing outside the EU.

The Talent Pool is intended to support recruitment into shortage occupations. It does not replace national immigration procedures, labor market tests or Member State admission rules. Participation by Member States remains relevant to the practical scope of the system.

Employers should monitor Member State participation and platform rollout, as the Talent Pool may become an additional pre-recruitment channel for roles affected by skills shortages.

Portugal

Key Changes to the Nationality Law

Portugal has introduced significant amendments to its Nationality Law, applicable to all applications submitted on or after May 19, 2026.

Under the new changes, the residence period required for naturalization is extended to seven (7) years for EU and Portuguese-speaking countries (CPLP) nationals and to ten (10) years for all other nationalities, replacing the former five (5) year standard. The law also tightens how residence time is calculated by counting only periods of lawful residence supported by valid work/residence permits and by starting the clock on the date the residence card is issued rather than the date of application.

Children born in Portugal now only qualify for citizenship if at the time of birth, at least one parent has completed five (5) years of legal residence and great‑grandchildren of Portuguese citizens may now qualify if they have lived legally in Portugal for at least five (5) years and can demonstrate a genuine connection to the Portuguese community. The changes also strengthen integration requirements by requiring applicants to show knowledge of Portuguese culture, history, national symbols, civic rights and duties, and to formally affirm their commitment to the democratic principles of Portugal.

For Golden Visa investors, the government has clarified that administrative delays should not negatively affect eligibility timelines, and pending nationality applications will continue to be assessed under the previous rules. Although the path to citizenship is now longer, Golden Visa holders remain eligible for permanent residence after five (5) years, and the program continues to offer a flexible route to long‑term residence without mandatory relocation.

Overall, the new framework underscores the importance of strategic planning for individuals and families considering long‑term residence or future citizenship in Portugal.

Sweden

New Work Permit Rules

On June 1, 2026, new Swedish work permit rules entered into force. The Swedish Migration Agency confirmed that the rules apply to first-time and extension work permit applicants, with certain transitional arrangements.

Under the new framework, the general salary requirement is set as at least 90% of the Swedish median salary at the time of application, while the salary must still meet collective agreement or industry-practice levels. Additional changes include a comprehensive health insurance requirement for stays of up to one year, extended EU Blue Card validity of up to four (4) years, and seasonal work permit validity of up to nine months within a 12-month period.

Employers should review salary levels, insurance coverage, and permit strategy before filing or extending work permit applications in Sweden.

Ireland

Employment Permit Occupation Lists Expanded

Ireland’s Department of Enterprise, Tourism and Employment announced a series of further changes to the employment permits system following the 2025 review of the Employment Permit Occupation Lists. The changes are intended to address labor shortages in sectors including construction, healthcare, transport, and agri-food.

The review resulted in the addition of six (6) occupations to the Critical Skills Occupations List. New Critical Skills occupations include Agronomists, Construction Planners/Schedulers, Geospatial Surveyors, certain Intellectual Property professionals, and Riggers (within the Games Industry). Additional occupations were removed from the Ineligible List, making them eligible for sponsorship under the General Employment Permit framework.

The changes expand recruitment options for employers experiencing skills shortages and may increase access to employment permits for roles that were previously ineligible or subject to restrictions. While the revised occupation lists expand access to sponsorship for a broader range of roles, employers must continue to satisfy existing employment permit requirements, including workforce composition requirements under the 50:50 rule (at least 50% of an employer’s workforce to be Irish, EEA, UK, or Swiss nationals for employment permits to be granted).

Netherlands

Revised EU Single Permit Directive

Dutch Immigration and Naturalization Service (IND) published guidance on the implications of revised EU Directive 2024/1233 on single permits. The revised Directive entered into force on May 22, 2026 and applies to several residence and work permit categories, including paid employment, highly skilled migrants, EU Blue Card holders, researchers, work experience permits, and orientation year permit holders.

The revised framework establishes new procedural requirements for employer changes and residence permit processing. The IND is generally required to decide qualifying employer-change cases within 45 days, subject to a possible extension of up to 15 days in exceptional circumstances. For certain initial residence permit applications, the statutory decision period may also be extended by up to 30 days where additional examination is necessary. EU Blue Card holders benefit from an expedited employer-change procedure, with decisions generally required within 30 days.

The amendments apply across several permit categories, including highly skilled migrants, EU Blue Card holders, researchers and certain single permit holders. Where the relevant notification or application requirements have been satisfied and all applicable conditions remain fulfilled, affected foreign nationals may commence employment with a new employer pending the IND’s decision. This arrangement is limited to the remaining validity period of the current residence permit.

The changes may reduce dependency on a single employer in some cases, but employers should continue to verify the conditions stated on the residence document and any applicable notification or filing requirements.

Estonia

Major Amendments to the Aliens Act Affecting Labor Shortage Sectors

Estonia adopted amendments to its immigration framework for the employment of foreign nationals in sectors experiencing labor shortages. The reforms are intended to support workforce needs in key industries while maintaining the existing annual immigration quota system. Implementation is phased, with certain provisions taking effect between May 2026 and January 2027.

Beginning on January 1, 2027, Estonia will introduce a dedicated framework for the recruitment of foreign nationals in sectors identified as experiencing labor shortages. Access to this route will be limited to employers whose principal economic activity falls within categories designated by the Government under the EMTAK classification system (EMTAK codes are Estonia’s national classification codes for economic activities, similar to NACE codes used across the EU).

Applications submitted under the new framework will be subject to a separate annual allocation and will no longer follow certain labor market verification procedures currently applicable to employment-based residence permits. Employers using this route will also be required to meet a minimum remuneration threshold linked to Estonia’s average gross monthly salary (at least 80% of Estonia’s average gross monthly salary, approximately 1,674 euros per month). The Government has not yet announced the sectors that will qualify under the new regime.

The amendments also abolish the temporary residence permit for short-term employment, while permits issued before January 1, 2027, will remain valid until their expiry or revocation. In addition, local governments will be required to monitor the lawful stay and employment of foreign nationals and report identified irregularities to the Police and Border Guard Board.

Companies should monitor the forthcoming Government decision identifying the eligible sectors, as the new regime will apply only to businesses whose principal economic activity falls within those designated EMTAK classifications.

Hungary

New Guest Worker Residence Permit Applications No Longer Accepted

Hungary has amended its immigration framework governing the employment of third-country nationals, resulting in the closure of the guest worker residence permit route for new filings starting from June 6, 2026. The change affects a permit category that has been widely used by certain employers to recruit foreign workers through designated employment structures.

The revised rules do not affect all employment-based residence permits. Individuals who already hold a guest worker residence permit may continue to rely on the existing framework for extension purposes, subject to the applicable conditions. Likewise, applications submitted before the new restrictions took effect will continue to be processed under the previous rules. Separate residence permit categories for employment remain available, including those accessible to nationals of specific countries identified under Hungarian legislation (i.e., Georgia, Armenia, and the Republic of the Philippines).

The measure is likely to reduce the availability of one of Hungary’s principal channels for hiring foreign workers and may require employers to reassess workforce planning strategies and available immigration routes. The change may be particularly relevant for companies relying on lower-skilled or agency-based foreign labor models.

Middle East

United Arab Emirates

New Wage Protection Rules Introduce Immigration-Related Compliance Risks

The UAE has introduced a revised Wage Protection System (WPS) framework, effective as of June 1, 2026. While the Resolution primarily governs the payment of employee wages, it also strengthens enforcement measures that may affect employers’ access to Ministry of Human Resources and Emiratization (MoHRE) services, including work permit processing.

Under the revised framework, employers must ensure wages are paid through the WPS within the prescribed timeframe and satisfy the applicable compliance threshold. Failure to comply may trigger progressively stricter administrative measures, including restrictions on the issuance of new work permits and other MoHRE services, depending on the duration of the breach.

Employers sponsoring foreign nationals in the UAE should review payroll processes to ensure continued compliance with the revised WPS requirements. Payroll non-compliance may have broader workforce planning implications by affecting an employer’s ability to obtain or renew work authorizations.

Jordan

Temporary Restrictions Introduced on New Foreign Worker Recruitment

Jordan has introduced temporary measures limiting the issuance of approvals for the recruitment of foreign workers in several economic sectors. The restrictions took effect on June 1, 2026 and form part of the Government’s efforts to regulate labor market participation and workforce planning.

Under the revised framework, employers in the affected sectors are generally no longer able to obtain new approvals to recruit foreign workers, subject to a few exceptions established by the Ministry of Labor (textiles industry, manufacturers, and occupations requiring specialized skills that are not sufficiently available in the local labor market, among others).

Companies with ongoing hiring needs should assess whether an exemption applies and consider the potential impact on recruitment timelines and workforce planning.

Africa

South Africa

Employment Services Amendment Bill Introduced

In June 2026, South Africa introduced the Employment Services Amendment Bill to Parliament. The Bill remains subject to the legislative process and has not yet been enacted.

The Bill would introduce a new framework on the employment of foreign nationals, including employer obligations to verify work authorization, confirm that the foreign national is permitted to perform the relevant work, retain visa and authorization records, and prepare a skills transfer plan unless excluded by ministerial determination. It would also allow sectoral or occupational quotas for the employment of foreign nationals, subject to further notices and consultation procedures.

Employers should monitor the bill because, if enacted, it would create additional recruitment, recordkeeping, and workforce planning obligations for companies employing foreign nationals in South Africa.

Algeria

Hague Apostille Convention Enters into Force on July 9, 2026

Democratic Republic of Algeria acceded to the Convention of 1961 Abolishing the Requirement of Legalization for Foreign Public Documents (Apostille Convention) on November 5, 2025. According to the Hague Conference on Private International Law, the Convention will enter into force for Algeria on July 9, 2026.

Once effective, public documents issued in Algeria and intended for use in other Apostille Convention countries may be authenticated through an Apostille certificate rather than the traditional legalization process involving multiple authorities and consular legalization. Likewise, apostilled documents issued in other contracting states will be recognized in Algeria under the Convention framework.

The change is expected to simplify document authentication procedures commonly required in immigration, employment, and educational and civil status applications.

Ghana

e-Visa Platform Launched and Visa Fees Waived for African Nationals

Ghana launched a new electronic visa platform for business and tourist travelers, allowing eligible applicants to complete the visa process online. Under the new framework, applicants submit supporting documentation electronically and, where applicable, pay the required fees online. Approved visas are issued electronically and delivered directly to applicants.

Authorities have indicated that complete applications are expected to be processed within 48 hours. In addition, African passport holders who require a visa to enter Ghana for business or tourism are now exempt from visa fees, although they must continue to obtain the appropriate travel authorization through the electronic platform. Existing arrangements remain unchanged for ECOWAS nationals (Economic Community of West African States), diplomatic passport holders, nationals benefiting from bilateral visa waiver agreements, and individuals applying under other immigration categories, such as student or family visas.

For additional information, please contact the EMEA Immigration team at EMEA@clarkhill.com

For further information on any of the updates in this bulletin, reach out to one of the members of our Outbound Immigration & Global Mobility team.

To view June’s updates for the Americas and APAC regions, click the respective region.

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